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Rules Published on COVID-19 Vaccine Mandate


In late October, the Departments of Treasury, Labor, and Health and Human Services issued a set of interim final regulations regarding the CARES Act requirement that group health plans cover COVID-19 vaccines at no cost to the participant. Under the legislation and rules, COVID-19 vaccines must be covered by non-grandfathered health plans as a preventive benefit, similar to preventive benefit requirements under the Affordable Care Act (ACA).


However, coverage of COVID-19 vaccines does have a few distinctions from regular preventive benefits. First, plans must begin to cover COVID-19 vaccines within 15 days of the United States Preventive Services Task Force (USPSTF) or the Centers for Disease Control and Prevention (CDC) recommending a vaccine. This this a much shorter timeframe than standard ACA preventive benefits rules, which give at least a year after the recommendation to begin coverage. Additionally, plans must cover the vaccine whether obtained at a network or out-of-network provider, in contrast to standard preventive benefits where the plan can limit services to a network provider. The rules further clarify that items and services that are integral to the furnishing of the vaccine, such as an office visit, must also be covered at no cost to the participant.


Unlike the COVID-19 testing mandate which expires at the end of the public health emergency, this vaccine mandate will continue indefinitely.


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